Formulators & importers of chemical mixtures
Companies that mainly buy in chemicals for manufacturing chemical mixtures or chemical products, such as paints and coatings, do not need to register the chemicals in their products
if they only use chemicals purchased within the EU, and
if the purchased chemicals have been registered or at least pre-registered.
Formulators and importers of preparations are responsible for registration of any chemical that they are using,
if they either synthesise their own chemicals, or
if they import chemicals from outside the EU, or
if a product contains a non-registered chemical.
Furthermore, a formulator or importer of a preparation has to make sure that his use of a chemical is covered by the Chemical Safety Report (CSR) within the registration of all used chemicals. If not, the user needs to contact the manufacturer of that chemical and request that his use of the chemical be included in the CSR - or he needs to prepare a CSR himself.
European Chemical Agency ECHA made available presentations that address the key issues of REACH and CLP affecting downstream users.
Please click here for a special guideline for importers, issued by Danish authorities, with contributions of, among others, Eurofins Product Testing A/S.
For consulting on above issues and design of any test program, please contact Eurofins